Consultation response
Autumn 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response
This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.
Issue 1e (i) - Reviewing limits and feedback on gambling activity: increasing and decreasing limits
Proposals
We consulted on the following proposals:
strengthening the wording of the current requirements around actioning customer requests to increase limits, by removing references of “all reasonable steps”
elevating current implementation guidance to a requirement that all customer requests to decrease a financial limit must be actioned immediately
an amendment to current implementation guidance that operators should inform customers when limits will take effect, if not automated or due to technical issues.
Consultation questions
To what extent do you agree with amended wording in relation to controls around actioning customers’ requests to increase limits?
To what extent do you agree with the proposal that customer-led reductions in limits must be implemented immediately?
To what extent do you agree with the revised wording of the implementation guidance, specifically to inform customers when the limit reduction will take effect, if not automated or due to technical issues?
Respondents’ views
Regarding these proposed amendments to the wording and elevating the status of the provisions from implementation guidance to requirements, a small number of respondents felt that there should be no allowance made for technical failures or issues, and some felt that the cooling off period should be longer than 24 hours. Some respondents commented that it was possible to circumvent the cooling off period for increasing limits by applying new limits of a different duration. The majority of respondents supported all 3 proposals.
Our position
Our view is that a minimum of 24 hours still presents sufficient delay to allow for reflection and preventing potentially impulsive decisions and is an example of friction being applied to the customer journey which is designed to be beneficial for consumers. A significantly longer mandated cooling-off period would reduce agility and responsiveness in the system which may lead to unintended consequences, such as customers avoiding setting limits or removing limits completely.
For the avoidance of doubt, customer-led actions such as applying a new limit of a different duration which would result in an immediate increase, or removing limits from the account, should be treated in the same manner as an increase to the limit and therefore subject to the same cooling-off period (during which the most restrictive limit would continue to apply) and confirmation by the customer that they wish to increase their limit.
We are proceeding with the introduction of the changes to the requirements and implementation guidance.
Final wording
This requirement will come into force on 31 October 2025.
Applies to: All gambling – except subscription lotteries.
RTS requirement 12D
Customer-led limits must only be increased at the customer’s request, only after a cooling-off period of at least 24 hours has elapsed and only once the customer has taken positive action at the end of the cooling off period to confirm their request.
Unless systems/technical failures prevent it, customer-led reductions to limits must be implemented immediately.
RTS implementation guidance 12D
In the event of systems or technical failure not facilitating an automated and/or immediate reduction in limits, the customer should be informed when the limit reduction will take effect.
Last updated: 4 February 2025
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